Establish the legal and product scope
A control map should list duties, accountable teams, legal triggers and evidence for payment reconciliation, notices, contact, forbearance, reporting and enforcement. Generic policy wording cannot show what occurred on a particular account. Review the regulated entity, agreement type, country and contractual terms before applying the relevant control. UK FCA CONC rules apply within their specified scope, not automatically throughout EU Member States. Distinguish binding law, regulatory guidance, internal policy and system coding. Identify the legal event that triggers action and record the applicable version of the rule. A correct account classification is necessary before communicating a consequence to a consumer or taking a servicing decision. The compliance file should identify which team owns the process and how a disputed fact will be investigated.
Reconcile source account records
Require source-led reconciliation before an arrears notice or significant collections action. Verify correct identity and balance under CONC 7.13, and preserve the record that informed the decision at the time. Trace the contractual instalments, actual payments, fees, interest, concessions and any account corrections. A collections dashboard might show an overdue balance without capturing an unallocated bank transfer or a recently agreed schedule. FCA CONC 7.13 requires relevant firms to maintain accurate and adequate data and verify it before pursuing a debt. Test whether the right borrower is identified and whether the sum demanded is correct. Record the source documents used, the time of reconciliation and any unresolved differences. Automated processing should be supported by a clear escalation route for exceptions.
Protect the consumer's ability to respond
Store the particular notice text, issue date, relevant account amount, delivery evidence and consumer reply. Separate ordinary reminders from statutory notices. Test accessibility and unsuccessful delivery without assuming that an uploaded PDF was received. Communications should accurately identify the responsible creditor or servicer, the obligation involved and the reason for contact. Explain an accessible way to dispute figures and provide additional evidence. A routine reminder, statutory notice, credit reference entry and enforcement measure are not interchangeable. Where a consumer has provided hardship information, a communication process should consider applicable forbearance obligations and the actual status of any arrangement. Do not threaten consequences that have not arisen. Keep the version of the communication actually sent and the resulting customer response for later review.
Assess hardship and disputed amounts
Record financial difficulty indicators lawfully, available repayment information, concessions considered and a reasoned outcome. Test that approved arrangements actually change account figures and stop inappropriate automated demands. A borrower may experience temporary income disruption, ongoing difficulty or a problem caused by inaccurate account information. Distinguish an allegation of incorrect charges from inability to pay; both may need attention. For relevant UK activities, CONC 7.3 concerns forbearance and due consideration where customers are in or approaching arrears or default. Staff should have access to relevant information about the consumer's circumstances, subject to data protection rules. Review the sustainability of proposed arrangements and whether account records correctly reflect agreed concessions. Record alternatives considered and reasons for the chosen response.
Manage system and third-party controls
Evaluate service provider instructions, handover records, sample communications, complaint corrections and debt sale files. Document which organisation can correct errors. Outsourcing cannot substitute for appropriate oversight of regulated obligations. Outsourcing, data transfers and automation can create gaps between legal responsibilities and operational decisions. Identify which firm owns the underlying account and which firm sends messages, posts payments, corrects records or handles complaints. FCA CONC 7.13 addresses accurate data supplied to persons involved in recovery and includes guidance on outsourcing. Maintain quality checks on interfaces and handovers, including how late corrections are applied. A vendor performance dashboard does not prove customers received correct information. Sample actual account histories and retained communications and track defects until verified as corrected.
Separate current law from CCD2 implementation
Prepare an obligation register for CCD2 Article 35 with national application and transitional dates. Keep UK FCA law separate from Member State requirements and identify which system controls need revision before implementation. Directive (EU) 2023/2225 Article 35 establishes a revised EU framework for reasonable forbearance before enforcement where appropriate, taking the individual's circumstances into account. Member State implementing measures generally apply from 20 November 2026, subject to transitional provisions. This framework does not make every UK FCA conduct rule a universal EU requirement. Examine relevant national legislation, product coverage and contract dates before changing operating rules. Maintain a separate list of current obligations and future implementation work. Avoid describing every possible concession in CCD2 as an unconditional entitlement for every borrower.
Test the evidence and correct recurring errors
Sample ordinary and exceptional cases, document findings and assign remediation owners. Recheck accounts after a defect is corrected. Retain historical evidence so supervisors can reconstruct the exact sequence rather than relying on a current dashboard. Sample ordinary cases and exceptions, including missing payments, disputed balances, hardship arrangements, mistaken identities and account transfers. For each sample, identify the rule, triggering event, ledger evidence, decision maker, communication and final outcome. Retain historical versions rather than relying on a current display that may conceal earlier mistakes. Monitor repeated issues for broader remediation and retest after corrective action. A robust record must allow a reviewer to reconstruct what happened on an individual account. Its purpose is to support accurate supervision and consumer treatment, not to certify compliance merely because documents exist.
Frequently asked questions
Does the same law apply to every EU country?
No. Current national law and the specific product must be checked.
What evidence is useful?
Historical account records, communications, legal sources and decision logs.
Primary sources
FCA CONC 7.13 ↗FCA CONC 7.3 ↗Directive (EU) 2023/2225 ↗Read the source in its current version. National implementing measures and product-specific applicability may require additional research.